Transportation Analysis Under CEQA

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Transportation Analysis under CEQAFirst Edition 2020 California Department of Transportation. All Rights Reserved.Evaluating Transportation Impacts ofState Highway System ProjectsCalifornia Department of TransportationSacramento, CaliforniaSeptember 2020

ACKNOWLEDGEMENTSThe Transportation Analysis Framework (TAF) and Transportation Analysis Under CEQA(TAC) were prepared by the California Department of Transportation working withState Administration partners and Stakeholders from the public, private and nonprofit sectors. Contributors within the Department included staff and managementfrom the Headquarters Divisions of Environmental Analysis, Transportation Planning,Traffic Operations, and Legal, as well as from the Director’s Office Sustainability Team.The Headquarters team benefitted from input provided by the Caltrans ExecutiveTeam as well as by staff and management from Caltrans districts.The documents are the products of a collaboration among State governmentpartners. Throughout the development of the documents, the Caltrans team workedclosely with technical and policy experts from the Governor’s Office of Policy andResearch and the California Air Resources Board.A list of the individuals who contributed to the preparation of the TAF and TAC isincluded at the end of this document. We are grateful for the time and effort thatthey generously gave to develop and document the Department’s new approachto analyzing and evaluating transportation impacts of projects on the State HighwaySystem.

LETTER FROM THE DIRECTORTo Caltrans staff, partners, and stakeholders,I am pleased to issue the enclosed guidance document:Transportation Analysis under the California EnvironmentalQuality Act (CEQA) for Projects on the State Highway System(TAC) as part of the California Department ofTransportation’s (Caltrans) continuing commitment toimplement the California Environmental Quality Act inalignment with State goals and policies. The TAC, and itscompanion document, Transportation Analysis Framework(TAF), provides Caltrans policy along with guidance forimplementing Senate Bill (SB) 743 (Steinberg, 2013) codifiedat Public Resources Code section 21099.The new processes implemented through Caltrans’ environmental program are akey part of Caltrans’ increasingly important work to confront the challenge ofclimate change and build more livable communities. Caltrans is activelyimplementing strategies to reduce emission of greenhouse gases, including initiativesto use clean fuels and vehicles, and to reduce waste. Perhaps most importantly, weare rethinking the way we invest so people can drive less.Reducing total driving, or vehicle miles traveled, is the focus of the TAC, TAF and theassociated changes to transportation impact analysis under CEQA for projects onthe State Highway System. In plain terms, the more we drive our cars, the moredamage we cause to the environment and our health—and the less time we spendwith our families and communities. A vehicle miles traveled-based approachsupports transportation projects that create more travel choices, such as new raillines, improved bus service, trails, paths, and safer streets for walking and bicycling.As these modes of transportation grow, we can reduce the dependence andburden on our already congested highway system.Thank you to our partners and stakeholders, as well as to Caltrans staff, whosecontributions have helped to shape this document. I look forward to your continuedpartnership as we make the changes needed to meet California’s goals for climate,air quality, and public health. It’s an exciting time to continue our commitment toprovide more transportation options to Californians and reduce our dependence ondriving.Sincerely,Toks OmishakinDirector, Caltrans

Transportation Analysis under CEQAFirst Edition September 2020TABLE OF CONTENTSTABLE OF CONTENTS . iLIST OF FIGURES AND TABLES. iiiFOREWORD . iv1INTRODUCTION/BACKGROUND . 12REGULATORY SETTING . 42.1 Sustainable Communities and Climate Protection Act of 2008 . 42.2 CEQA Guidelines. 53OTHER RELEVANT DOCUMENTS AND REFERENCES . 73.1 Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR Technical Advisory)73.2 California Air Resources Board Climate Change Scoping Plan . 73.3 California Air Resources Board’s Mobile Source Strategy. 73.4 California Air Resources Board’s Sustainable Communities and Climate Protection ActProgress Report . 84PROJECT SCOPING . 95THE CEQA ANALYSIS . 115.1 Screening .115.2 Baseline Determination .165.3 Direct Impacts to Vehicle Miles Traveled, Including Induced Travel . 185.4 Cumulative and Indirect Impacts. 205.5 Consistency with Plans .215.6 Determining Significance .215.7 Mitigation .225.8 Related Mitigation .265.9 Statements of Overriding Considerations .26APPENDIX A. CONSIDERATIONS FOR STATEMENTS OF OVERRIDINGCONSIDERATIONS. 28APPENDIX B. CEQA GUIDELINES, APPENDIX G CHECKLIST QUESTIONS. 29APPENDIX C. MITIGATION. 31Literature Review and Assessment of VMT and GHG Mitigation Strategies . 33APPENDIX D-1. EXAMPLE PROJECT 1: CONSTRUCTION OF HIGH-OCCUPANCYVEHICLE (HOV) LANES IN SUNSHINE COUNTY . 38 2020 California Department of Transportation. All Rights Reserved.i

Transportation Analysis under CEQAFirst Edition September 2020APPENDIX D-2. EXAMPLE PROJECT 2: CONSTRUCTION OF TRUCK CLIMBINGLANES IN RAINBOW COUNTY . 44APPENDIX E. GLOSSARY OF ACRONYMS AND TERMS . 47APPENDIX F. ACKNOWLEDGEMENTS . 50 2020 California Department of Transportation. All Rights Reserved.ii

Transportation Analysis under CEQAFirst Edition September 2020LIST OF FIGURES AND TABLESFigure 1. Relationship Between the TAC and TAF Documents .3Figure 2. Identification of Induced Travel. 13Table 1. Selection Matrix for Preferred Induced Travel Assessment Method forProjects on the SHS. 19Table 2. Project-Level Measures to Reduce VMT on the SHS . 26APPENDIX FIGURES AND TABLESFigure C-1. Chart 6-2 of the CAPCOA Report . 32Table C-1. Mitigation Strategies by Caltrans Role . 34Table C-2. Quantifiable mitigation strategies with respect to VMT/GHG . 34Figure D-1. Example Project Map . 39Table D-1. Project Alternatives and VMT Evaluation . 41 2020 California Department of Transportation. All Rights Reserved.iii

Transportation Analysis under CEQAFirst Edition September 2020FOREWORDThe Transportation Analysis Framework (TAF) and Transportation Analysis under CEQA(TAC) guide transportation impact analysis for projects on the State Highway System(SHS) as part of the California Environmental Quality Act (CEQA) process. TheCalifornia Department of Transportation (Caltrans) has prepared these documentsto guide implementation of Senate Bill (SB) 743 (Steinberg, 2013). The TAF and TACestablish Caltrans guidance on how to analyze induced travel associated withtransportation projects and how to determine impact significance under CEQA,respectively. These documents guide transportation impact analysis for projects onthe SHS only. The non-capacity-increasing maintenance projects like re-paving andfilling potholes are unaffected, as are many safety improvements, including trafficcalming measures to slow traffic, and transportation projects that create facilities forpedestrians and cyclists and transit projects.In response to a high level of interest in the guidance from Caltrans’ transportationpartners, climate and environmental advocates and others, Caltrans has hosted atotal of 130 meetings with stakeholders and provided a 60-day informal feedbackperiod on the draft documents. Statewide outreach events included two externalwebinars attended by over 850 participants and three external technicalroundtables attended by more than 150 participants. These Caltrans events weresupplemented by OPR’s webinar and Office Hours outreach which reached over3,500 participants. Additionally, Caltrans met regularly through the guidancedevelopment process with key stakeholders including the Self-help CountiesCoalition, the ClimatePlan coalition, and the Rural Counties Task Force.Caltrans received feedback on the drafts from 37 agencies including counties, cities,and MPOs as well as from consultants, advocates, coalitions and other Stateagencies. Throughout the process, a small number of controversial issues stood out.To address the difference of opinions around key technical issues, Caltransconvened an expert panel of academics and practitioners through UC BerkeleyTech Transfer. The panel chair presented the group’s conclusions to stakeholders ata virtual Technical Roundtable prior to finalizing the group’s recommendations.Caltrans and State partners have accepted the panel’s recommendations, whichare reflected in the guidance documents.The Caltrans TAF and TAC guidance documents reflect a cultural shift in how Caltransinterprets, analyzes and mitigates transportation impacts. This shift will impact theentire project delivery process and shape the future of California’s transportationsystem. The September 2020 TAF and TAC are the first versions of these materials, andwe anticipate future improvement as our understanding and expertise deepensthrough implementation. Your continuing input and partnership with Caltrans willhelp further improve the guidance. Your commitment and participation in thisongoing work is appreciated. 2020 California Department of Transportation. All Rights Reserved.iv

Transportation Analysis under CEQAFirst Edition September 20201 INTRODUCTION/BACKGROUNDThe intent of this guidance is to provide information to support Caltrans’ CEQApractitioners in making CEQA significance determinations for transportation impactsof projects on the SHS.With the passage of Senate Bill (SB) 743 (Steinberg, 2013) codified at Public ResourcesCode (PRC) section 21099, California embarked on a new approach for analyzingtransportation impacts under CEQA. These changes require updates to both theCaltrans Local Development-Intergovernmental Review (LD-IGR) function andproject delivery for projects on the SHS.In SB 743, the California State Legislature (Legislature) found and declared thefollowing:(1) With the adoption of Chapter 728 of the Statutes of 2008, popularlyknown as the Sustainable Communities and Climate Protection Act of2008, the Legislature signaled its commitment to encouraging land useand transportation planning decisions and investments that reducevehicle miles traveled and contribute to the reductions in greenhousegas emissions required in the California Global Warming Solutions Act of2006 (Division 25.5 (commencing with Section 38500) of the Health andSafety Code). Similarly, the California Complete Streets Act of 2008(Chapter 657 of the Statutes of 2008) requires local governments to planfor a balanced, multimodal transportation network that meets theneeds of all users of streets, roads, and highways for safe and convenienttravel.(2) Transportation analyses under the California Environmental Quality Act(Division 13 (commencing with Section 21000) of the Public ResourcesCode) typically study changes in automobile delay. Newmethodologies under the California Environmental Quality Act areneeded for evaluating transportation impacts that are better able topromote the state’s goals of reducing greenhouse gas emissions andtraffic-related air pollution, promoting the development of a multimodaltransportation system, and providing clean, efficient access todestinations.The legislative intent of SB 743 is to do both of the following:1) Ensure that the environmental impacts of traffic, such as noise, air pollution,and safety concerns, continue to be properly addressed and mitigatedthrough the CEQA.2) More appropriately balance the needs of congestion management withstatewide goals related to infill development, promotion of public healththrough active transportation, and reduction of greenhouse gas (GHG)emissions. 2020 California Department of Transportation. All Rights Reserved.1

Transportation Analysis under CEQAFirst Edition September 2020In December 2018, the Office of Administrative Law approved updates to the formalCEQA regulations prepared by OPR. The formal regulations are generally referred toas the CEQA “Guidelines.” The update contained, among other things, a newsection 15064.3 addressing transportation impacts. OPR also released the TechnicalAdvisory on Evaluating Transportation Impacts in CEQAwhich containsrecommendations on assessing vehicle miles traveled (VMT), significance, andmitigation measures.1Section 15064.3 of the Guidelines separately addresses the analysis of transportationimpacts arising from land use projects and those arising from transportation projects.For Caltrans, SB 743 means major changes in two activities:1)2)Review of a proposed land use project’s or a proposed plan’s potentialimpact to the SHS, which are generally addressed through the CaltransLocal Development-Intergovernmental Review Program.CEQA analysis of capacity-increasing transportation projects on the SHS.These changes are consistent with both the CEQA Guidelines and OPR’s TechnicalAdvisory. Together, they aim to reduce automobile use while increasing use of moresustainable modes of transportation that are essential to supporting our growingpopulation and economy, while also meeting climate goals. Reducing VMTcorresponds with the goals detailed in Caltrans’ Strategic Management Plan. It is alsoconsistent with and will aid Caltrans in continuing to meet its policy aims for theEnvironment (Director’s Policy [DP-004]); Freeway System Management (DP-08);Energy Efficiency, Conservation, and Climate Change (DP-023-R1); Climate Change(DP-30); and Sustainability (DP-033), among others.This guidance establishes Caltrans’ process for analyzing a transportation project’simpacts under CEQA due to increases in VMT attributable to that project and offersan initial list of potential mitigation measures for significant impacts. This guidanceaugments but does not change any of the basic processes currently in place forevaluating projects under CEQA and other applicable laws or regulations. Thisguidance is not intended to address transportation impacts resulting from land-useprojects which are addressed in the separate Transportation Impact Study Guide(TISG). Nor is this guidance intended to provide detailed instruction on performingthe induced travel analysis itself, which can instead be found in the TransportationAnalysis Framework (TAF).The TAC is to be used in conjunction with the guidance provided in the TAF. The flowchart provided as Figure 1 illustrates the relationship between the TAC and TAF.Office of Planning and Research, Technical Advisory on Evaluating Transportation Impacts in CEQA(December 2018).1 2020 California Department of Transportation. All Rights Reserved.2

Transportation Analysis under CEQAFirst Edition September 2020Figure 1. Relationship Between the TAC and TAF Documents 2020 California Department of Transportation. All Rights Reserved.3

Transportation Analysis under CEQAFirst Edition September 20202 REGULATORY SETTINGThis section contains a listing of relevant laws, regulations, documents, andreferences for project-level VMT analysis.Regional VMT analysis takes place during the development of the RegionalTransportation Plans (RTPs), which are prepared and adopted every five years by the26 rural Regional Transportation Planning Agencies (RTPAs), and every four years forthe 18 Metropolitan Planning Organizations (MPOs) located in air quality nonattainment areas and at least every five years for MPOs located in air qualityattainment areas. An RTP is a long-range, fiscally constrained plan prepared subjectto federal and State requirements. It provides a vision for regional transportationinvestments over a period of 20 years or more and analyzes the transportation systemand its relationships to a region’s economy, environment, livability, and more.2.1 SUSTAINABLE COMMUNITIES AND CLIMATE PROTECTION ACT OF 2008Senate Bill 375 (Steinberg), known as the Sustainable Communities and ClimateProtection Act, was enacted in 2008. SB 375 directed the California Air ResourcesBoard (CARB) to adopt regional GHG emissions reduction targets applicable to eachMPO region. SB 375 also required the State’s 18 MPOs to: 1) prepare a sustainablecommunities strategy (SCS) to achieve the GHG-reduction target as part of the RTP;or 2) prepare an “alternative planning strategy” if the SCS does not achieve thereductions called for by the regional targets.Senate Bill 375 also required the California Transportation Commission, in conjunctionwith CARB, to maintain guidelines for the travel demand models used in thedevelopment of RTPs.Each RTPA or MPO must also complete an environmental analysis of its RTP pursuantto CEQA. These environmental documents analyze the anticipated environmentaleffects arising from the implementation of the region’s RTP, including transportationimpacts. The environmental documents prepared by the RTPAs and MPOs report avariety of VMT-related metrics or performance measures in their analyses includingtotal annual VMT, per capita VMT, and congested VMT. 2020 California Department of Transportation. All Rights Reserved.4

Transportation Analysis under CEQAFirst Edition September 20202.2 CEQA GUIDELINESSection 15064.3 of the CEQA Guidelines (Guidelines) addresses Project-level VMTanalysis under CEQA.The portion of the Guidelines that address transportation projects (rather than landuse projects), begins at section 15064.3(b) and reads:(2) Transportation Projects. Transportation projects that reduce, or haveno impact on, vehicle miles traveled should be presumed to cause aless than significant transportation impact. For roadway capacityprojects, agencies have discretion to determine the appropriatemeasure of transportation impact consistent with CEQA and otherapplicable requirements. To the extent that such impacts have alreadybeen adequately addressed at a programmatic level, such as in aregional transportation plan EIR, a lead agency may tier from thatanalysis as provided in Section 15152.(3) Qualitative Analysis. If existing models or methods are not availableto estimate the vehicle miles traveled for the particular project beingconsidered, a lead agency may analyze the project’s vehicle milestraveled qualitatively. Such a qualitative analysis would evaluate factorssuch as the availability of transit, proximity to other destinations, etc. Formany projects, a qualitative analysis of construction traffic may beappropriate.(4) Methodology. A lead agency has discretion to choose the mostappropriate methodology to evaluate a project’s vehicle milestraveled, including whether to express the change in absolute terms, percapita, per household or in any other measure. A lead agency may usemodels to estimate a project’s vehicle miles traveled, and may revisethose estimates to reflect professional judgment based on substantialevidence. Any assumptions used to estimate vehicle miles traveled andany revisions to model outputs should be documented and explained inthe environmental document prepared for the project. The standard ofadequacy in Section 15151 shall apply to the analysis described in thissection.Several broader observations about section 15064.3 and how it relates to thisguidance are important to note:·Per section 15064.3, VMT is “Generally the most appropriate measure oftransportation impacts.” The simplest definition of VMT, or vehicle miletraveled, is “One vehicle traveling on a roadway for one mile” (SacramentoArea Council of Governments 2016 MTP/SCS). Section 15064.3(a) defines“vehicle miles traveled” as “The amount and distance of automobile travelattributable to a project.” This is a significant change from previous 2020 California Department of Transportation. All Rights Reserved.5

Transportation Analysis under CEQAFirst Edition September 2020methodologies which typically analyzed Level of Service (LOS)2, a travel timeand congestion metric, as the most important consideration in transportationimpacts analysis. When evaluating transportation impacts on the SHS, Caltranswill now evaluate the “induced travel,” or the change in VMT attributable toan individual transportation project.·Certain project types, primarily those which are non-capacity increasing, arepresumed to result in a less than significant transportation impact andtherefore generally do not require analysis of vehicle miles traveled. Thoseproject types are discussed in section 5.1 of this document and are alsodescribed in the OPR Technical Advisory.·A lead agency may in some cases tier its transportation impact analysis, asappropriate, from the environmental impact reports (EIRs) prepared forregional transportation plans/sustainable community strategies (RTP/SCS).3See the discussion in section 5.1.2. of this document to assess whethertransportation impacts have been adequately analyzed at the programmaticlevel, and whether tiering from an RTP/SCS EIR or other analysis may beappropriate.·Quantitative analysis is most appropriate for transportation projects whichincrease roadway capacity. Please refer to Section 4 of the TAF for furtherdiscussion.·Qualitative analysis may be appropriate for certain transportation projects,particularly when technical models are not available, as discussed in TAFSection 4. The use of a qualitative analysis should generally be limited to thosesituations in which quantitative tools are unable to adequately assess atransportation project’s impacts. Please refer to Section 4 of the TransportationAnalysis Framework: Induced Travel Analysis (TAF) for more details.Caltrans has chosen to express change in VMT in absolute terms.The Highway Capacity Manual, which first introduced the concept of LOS in 1965, defines LOS asfollows: “Level of service (LOS) is a quality measure describing operational conditions within a trafficstream, generally in terms of such service measures as speed and travel time, freedom to maneuver,traffic interruptions, and comfort and convenience. Safety is not included in the measures thatestablish service levels.” Additionally, “each facility type that has a defined method for assessingcapacity and level of service also has performance measures that can be calculated. Thesemeasures reflect the operating conditions of a facility, given a set of roadway, traffic, and controlconditions. Travel speed and density on freeways, delay at signalized intersections, and walkingspeed for pedestrians are examples of performance measures that characterize flow conditions ona facility” (Highway Capacity Manual, 2000).3 It should be noted that some RTPs/SCSs are not consistent with the state’s climate goals, accordingto CARB. See CARB, “CARB 2017 Scoping Plan,” 4. A close review of the applicable EIR for the RTPwill be required in order to “tier” from its analysis.2 2020 California Department of Transportation. All Rights Reserved.6

Transportation Analysis under CEQAFirst Edition September 20203 OTHER RELEVANT DOCUMENTS AND REFERENCES3.1 TECHNICAL ADVISORY ON EVALUATING TRANSPORTATION IMPACTS INCEQA (OPR TECHNICAL ADVISORY)The OPR Technical Advisory provides recommendations on assessing VMT,significance, and mitigation measures. Practitioners should consult the OPRTechnical Advisory when evaluating transportation impacts of projects on the SHS.3.2 CALIFORNIA AIR RESOURCES BOARD CLIMATE CHANGE SCOPING PLANIn 2006, the Legislature passed Assembly Bill 32 (AB 32, Nunez), known as theCalifornia Global Warming Solutions Act of 2006. which created a comprehensive,multi-year program to reduce GHG emissions in California. AB 32 required CARB todevelop the Scoping Plan to describe the approach California would take to reduceGHGs to meet the target of reducing emissions to 1990 levels by 2020. The ScopingPlan was first approved by CARB in 2008 and updated in 2014 and again in 2017. 4In 2016, the Legislature passed SB 32 (Pavley), which codified a statewide 2030 GHGemissions-reduction target of 40 percent below 1990 levels. Along with SB 32, theLegislature passed companion legislation, AB 197 (Eduardo Garcia), which providedadditional direction for updating the Scoping Plan. These changes were reflected inthe second update to the Scoping Plan completed in 2017.3.3 CALIFORNIA AIR RESOURCES BOARD’S MOBILE SOURCE STRATEGYIn May 2016, CARB released the updated Mobile Source Strategy whichdemonstrates how the State can simultaneously meet air quality standards, achieveGHG emissions reduction targets, decrease health risk, and reduce petroleumconsumption from the transportation sector through a modeling scenario—the“Cleaner Technologies and Fuels Scenario” (CTF). Although the majority of GHGreductions in the scenario are assumed to be attributable to new vehicletechnologies and low carbon fuels, the CTF also demonstrates the need for a 15percent reduction in total light-duty VMT by 2050 as compared to baseline 2050levels. This scenario would require light-duty VMT growth of only five percent by 2030,compared to the current growth trajectory of approximately 11 percent.5 Thecombined strategies within the CTF scenario, including VMT reduction, wouldachieve a 45 percent reduction in on-road GHG emissions by 2030, and anCalifornia Air Resources Board, “2017 Scoping Plan Documents.” Available nts.5 California Air Resources Board, “Mobile Source Strategy,” (May 2016), 37.4 2020 California Department of Transportation. All Rights Reserved.7

Transportation Analysis under CEQAFirst Edition September 2020approximately fifty percent reduction in on-road petroleum demand by 2050,meeting both climate targets. CARB continues to implement the 2016 Mobile SourceStrategy and in 2020 is in the process of updating the Strategy, as required by SenateBill 44 (Skinner).63.4 CALIFORNIA AIR RESOURCES BOARD’S SUSTAINABLE COMMUNITIES ANDCLIMATE PROTECTION ACT PROGRESS REPORTIn November of 2018, CARB published the “2018 Progress Report: California’sSustainable Communities and Climate Protection Act” (Progress Report). TheProgress Report indicates California is not on track to meet the GHG reductionsexpected under SB 375. According to the Progress Report, actual statewide percapita VMT had not declined as expected under SB 375 but at the time the reportwas written, was increasing. The fundamental finding in CARB’s Progress Report is thatCalifornia is not on track to meet GHG emissions reductions expected under SB 375and will not meet SB 32 GHG emissions targets without significant changes to howcommunities and transportation systems are planned, funded, and built. 7California Air Resources Board, “2020 Mobile Source Strategy.” Available mobile-source-strategy.7 California Air Resources Board, “2018 Progress Report: Sustainable Communities and Cli

Sep 10, 2020 · Transportation Analysis under the California Environmental Quality Act (CEQA) for Projects on the State Highway System (TAC) as part of the California Department of Transportation’s (Caltrans) continuing commitment to implement the California Environmental Quality Act in

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